International Taxation in a Nutshell

This Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been revised and updated to reflect the passage of the One Big Beautiful Bill Act passed in July 2025, along with other regulatory developments and recent court decisions. It also includes a discussion of developments in the tax rules as applied to new technologies, including crypto and digital. Both the U.S. activities of foreign taxpayers, as well as the foreign activities of U.S. taxpayers are explored. In addition to providing a survey of the technical rules, the book also offers insight into tax planning considerations and how these have been impacted by U.S. and global developments. Referenced throughout are recent global tax developments and how OECD and UN rules and proposals interact with the U.S. international tax regime. In today’s world, it is crucial for those involved in business and investment activities to understand the tax consequences of cross-border flows. The book has been updated with a new chapter on non-income taxes as they affect cross-border trade, including the intersection of the income tax rules and the tariffs. The author’s career spans the academic and private sectors, and she has used (more...)